Part 9Partnerships

Firms with a foreign element

858Resident partners and double taxation agreements

(1)

This section applies if—

(a)

a UK resident (“the partner”) is a member of a firm which—

(i)

resides outside the United Kingdom, or

(ii)

carries on a trade the control and management of which is outside the United Kingdom, and

(b)

by virtue of any arrangements having effect under F1section 2(1) of TIOPA 2010 (“the arrangements”) any of the income of the firm is relieved from income tax in the United Kingdom.

(2)

The partner is liable to income tax on the partner's share of the income of the firm despite the arrangements.

F2(3)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

F3(4)

For the purposes of this section the members of a firm include any person entitled to a share of income of the firm.